**wrk2play productions, llc 2085 South 50 East**  **Wanship, Utah 84017**
United States of America Department of Transportation Federal Aviation Administration Washington, D.C. 20591 wrk2play productions, llc petitions for a Grant of Exemption so that the company c an conduct aerial photography, videography and cinematography f or companies/individuals seeking such service. It is in the best interest of the community and the company to have the exemption granted so that all flights are conducted in a safe, lawful and responsible manner. Specifically we request an exemption from part 21, subpart H; and Sections 45 .23 (b), 61.113(a) and (b), 91.7(a), 91.9(b)(2) , 91.103(b), 91.109, 91.119, 91.121, 91
. 151 (a), 91
. 203(a) and (b), 91.405(a), 91.407(a)(1), 91.409(a)(2), and 91.417(a) and (b) of Title 14, Code of Federal Regulations (14 CFR)

. These flights would be conducted using either a DJI Phantom Pro 3 or a Yuneec Electric Aviation Ty

phoon Q5004K, both aircraft having integral gimbal s and cameras . Future aircrafts to be used could include a DJI Inspire, DJI Inspire Pro , DJI Spreading Wing 900, DJI Spreading Wings 1000 , Yuneec Electric Aviation H920 , 3DR Solo and Yuneec Electric Aviation Ty phoon H
. With Safety

b eing our primary goal, we look at this operation as a safer alternative to operating larger petroleum powered aircraft requiring airborne crewmembers. To ensure that we can meet those requirements we will make sure that all our PICs have at least a private pilots certificate with a current FAA class 3 physical or a current and valid state drivers license. In addition we will insist that all PICs go through our ground training program that will cover the operation of the specific UAS they will be operating, weather requirements, UAS system operations both normal and emergency. The training will also cover the importance of documenting both the flight hours of the PIC and the UAS
. Special emphasi s will be put on documenting any and all maintenance discrepancies and the importance of properly documenting the resulting corrective action prior to any flight. In addition, we believe that every PIC needs to have accumulated at least 5 hours of UAS time. To maintain prof iciency we will make sure the PIC makes at least 3 take offs and landings within a 90

- day time frame and all these requirements will be documented in the Pilots logbook

. To ensure we do not interfere with any other manned aircraft we will not fly a bove 400 ' or within 5 miles of any airport unless we are in radio contact with the control tower or prior coordination. To ensure all are known of our presence , we will post all flights on NOTAMS when conducting commercial operations and will , advise all local residents if applicable of impending flights

. On the day o f the flight we will post signage indicating that a UAS flight is in the immediate area. As for the actual UAS operation we will require that all PICs complete a preflight safety check of the UAS that will ensure all components of the system work as required

. Part 21 prescribes the procedural requirements for issuing and changing design approvals, productions approvals, airworthiness certificates, and airworthiness approvals 2.- 2

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Section 45.23(b) prescribes that when marks include only the Roman capital letter “N” and the registration number is displayed on limited, restricted or light

- sport category aircraft or experimental or provisionally certificated aircraft, the operator must also display on that aircraft near each entrance to the cabin, cockpit, or pilot station, in letters not less than 2 inches nor more than 6 inches high, the words “limited,” “restricted,” “light

- sport,” “experimental,” or “provisional,” as applicable. Because of the size of the aircraft, we propose to install the “N” on the fuselage but do not think there is adequate space to also place any of the categories mentioned Section 61.113(a) and (b) prescribes that

— (a) no person who holds a private pilot certificate may act as a pilot in command of an aircraft that is carrying passengers or property for compensation or hire; nor may that person, for compensation or hire, act as pilot in command of an aircraft. (b) a private pilot may, for compensation or hire, act as pilot in command of an aircraft in connection with any business or employment if: (1) The flight is only incidental to that business or employ ment; and (2) The aircraft does not carry passengers or property

for compensation or hire. Since we will not be carrying any passengers or property for compensation we believe a private pilot can carry out the responsibilities of the PIC. Section 91.7(a) prescribes that no person may operate a civil aircraft unless it is in an airworthy condition. An exemption is requested to 91.7(a) because the UA S does not have to receive an airworthy condition by the FAA. Section 91.7(b) prescribes that the pilot in command of a civil aircraft is responsible for determining whether that aircraft is in condition for safe flight and that the PIC shall discontinue the flight when un airworthy mechanical, electrical, or structural conditions occur. We will terminate any flight when the aircraft becomes un-airworthy with mechanical, electrical or structural conditions. There is no exception

. Section 91.9(b)(2) prohibits operation of U.S.

-registered civil aircraft unless there is available in the aircraft a current approved Airplane or Rotorcraft Flight Manual, approved manual material, markings, and placards, or any combination thereof. There is no FAA approved manual for the Phantom 3/Q5004 K but we are submitting the following that we feel will suffice. Quick start check list and user manual and basic frequency information approved by the FCC

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Section 91.103(b) prescribes that a pilot shall for any flight, become familiar with runway lengths at airports of intended use, and takeoff and landing distance information. The Phantom 3/

Q5004K does not use any runway for take off and the company policy is that the Phantom 3/Q5004K will remain clear of all ramps, taxiways and runways associated with any airport if applicable. Section 91.109(a) prescribes, in pertinent part, that no person may operate a civil aircraft (except a manned free balloon) that is being used for flight instruction unless that aircraft has fully functioning dual controls. The Phantom 3/Q5004K does not have dual flight controls and all instruction is via the one controller. We therefore request an exemption from this requirement

. Section 91.119 prescribes that, except when necessary f or takeoff or landing, no person may operate an aircraft below the following altitudes. (a) Any where. An altitude allowing, if a power unit fails, an emergency landing without undue hazard to persons or property on the surface. We will not operate the Phantom 3/Q5004K near any power lines, light post s or any other powered obstacle unless requested in the form of a COA. (b) Over congested areas. Over any congested area of a city, town, or settlement, or over any open air assembly

of persons, an altitude of 1,000 feet above the highest obstacle within a horizontal radius of 2,000 f eet of the aircraft. We will not operate the Phantom 3/Q5004K over any congested areas. (c) Over other than congested areas. An altitude of 500 feet above the surface, except over open water or sparsely populated areas. In those cases, the aircraft may not b e operated closer than 500 feet to any person, vessel, vehicle, or structure. Because of small size of the Phantom 3/Q5004K and the fact that there is no fuel on board we believe as how we offer no risk to flying less than 500 feet in other than congested areas. We would like to operate like powered parachutes in that we will ensure that we do not present any hazard to persons or property on the surface. In addition we will ensure we have permission from the owner of any vehicle or property prior to getting within the 500 ft. area. (d) Helicopters, powered parachutes, and weight

- shift

- control aircraft. If the operation is conducted without hazard to persons or property on the surface

— (1) A helicopter may

b e operated at less than the minimums prescribed in paragraph (b) or (c) of this section, provided each person operating the helicopter complies with any routes or altitudes specifically prescribed for helicopters by the FAA; and (2) A powered parachute or weight

- shift

- control aircraft may b e operated at less than the minimums prescribed in paragraph (c) of this section.- 4

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Section 91.121 requires, in pertinent part, each person operating an aircraft to maintain cruising altitude by

reference to an altimeter that is set “...to the elevation of the departure airport or an appropriate altimeter setting available before departure.” The Phantom 3/Q5004K does not have a barometric altimeter but uses GPS signals to compute altitude. We will set the altitude to zero prior to take off so as to be able to know altitude above the ground at all times. Section 91.151(a) prescribes that no person may b egin a flight in an airplane under VFR conditions unless (considering wind and forecast weather conditions) there is enough fuel to fly to the first point of intended landing and, assuming normal cruising speed, (1) during the day, to fly after that for at least 30 minutes [emphasis added.]. Since the Phantom 3/Q5004K does not carry fuel but uses battery power we request the following. The battery on the Phantom 3/Q5004K has lights that come on when the battery is at 30% power and we would like to use that as the planning to return for a safe landing. Most of our f lights will n o t exceed 10

-20 min utes in f light and since the battery has a normal 25

-minute range this 30% factor should provide a safe return point. We will ensure that all flights consider winds in determining their return point as they could have a head wind on return. Section 91.203(a) prohibits, in pertinent part, any person from operating a civil aircraft unless it has within it (1) an appropriate and current airworthiness certificate; and (2) an effective U.S. registration certificate issued to its owner or, for operation within the United States , the second copy of the Aircraft registration Application as provided for in § 47.31(c). An exemption is requested for the airworthiness requirement since the Phantom 3/Q5004K does not have an airworthiness certificate

. Section 91.203(b) prescribes, in pertinent part, that no person may operate a civil aircraft unless the airworthiness certificate or a special flight authorization issued under § 91.715 is displayed at the cabin or cockpit entrance so that it is legible to passengers or crew. Since there is no requirement for an airworthiness certificate for the Phantom 3/Q5004K this requirement would not be appropriate. In addition because of the size of the aircraft there is just not a place to display the certificate. Section 91.405(a) requires, in pertinent part, that an aircraft operator or owner shall have the aircraft inspected as prescribed in subpart E of the same part and shall, between required inspections, except as provided in paragraph (c) of the same section, have discrepancies repaired as prescribed in part 43 of the chapter.4 There is no approved maintenance program for the Phantom 3/Q5004K but we will ensure that it goes through a complete post flight inspection after every flight

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Section 91.407(a)(1) prohibits, in pertinent part, any p erson from operating an aircraft that has undergone maintenance, preventive maintenance, rebuilding, or alternation unless it has been approved for return to service by a person authorized under § 43.7 of the same chapter. After any maintenance that requires change of engine or propeller that aircraft will undergo a test flight by the PIC in a remote unpopulated area to ensure the aircraft is operating safely. Section 91.409(a)(2) prescribes, in pertinent part, that no person may operate an aircraft unless, within the preceding 12 calendar months, it has had an inspection for the issuance of an airworthiness certificate in accordance with part 21 of this chapter. After any maintenance that requires change of engine or propeller that aircraft will undergo a test flight by the PIC in a remote unpopulated area to ensure the aircraft is operating safely. Section 91.417(a) and (b) prescribes, in pertinent part, that

— (a) Each registered owner or operator shall keep the following records for the periods specified in paragraph (b) of this section: (1) Records of the maintenance, preventive maintenance, and alternation and records of the 100

-hour, annual, progressive, and other required or approved inspections, as appropriate, for each aircraft (including the airframe) and each engine, propeller, rotor, and appliance of an aircraft. The records must include

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(i) A description (or reference to data acceptable to the Administrator) of the work performed; and

(ii) The date of completion of the work performed; and (iii) The signature, and certificate number of the person approving the aircraft for return to service. (2) Records containing the following information: (i) The total time in service of the airframe, each engine, each propeller and each rotor. (ii) The current status of life

-limited parts of each airframe, engine, propeller, rotor, and appliance. (iii) The time since last overhaul of all items installed on the aircraft which are required to be overhauled on a specified time basis. (iv) The current inspection status of the aircraft, including the time since the last inspection required by the inspection program under which the aircraft and its appliances are maintained.5 (v) The current status of applicable airworthiness directives (AD) and safety directives including, for each, the method of compliance, the AD or safety directive number and revision date. If the AD or safety directive involves recurring action, the time and date when the next action is required. (vi) Copies of the forms prescribed by § 4 3.9(d) of this chapter for each major alternation to the airframe and currently installed engines, rotors, propellers, and appliances.- 6

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(b) The owner or operator shall retain the following records for the periods prescribed: (1) The records specified in paragraph (a)(1) of this section shall be retained until the work is repeated or superseded by other work or for 1 year after the work is performed. (2) The records specified in paragraph (a)(2) of this section shall be retained and transferred with the aircraft at the time the aircraft is sold. (3) A list of defects furnished to a registered owner or operator under § 43.11 of this chapter shall be retained until the defects are repaired and the aircraft is approved for return to service. We will maintain an aircraft logbook and electronic telemetry that will reflect all flight time on the UA S

, any and maintenance performed on the UAS . There are no life

- limited parts on the Phantom 3/

Q5005K , no system of AD. If we are notified by the manufacture (D JI) (Y uneec Electric A viation

) that there is a discrepancy we will rectify it and annotate prior to the next flight if it relates to flight safety.

wrk2play productions, llc provides the following supporting documentation including pre- flight checklists for the Phantom 3 and Q5004K, original manufacture instruction guides and (all Radio Frequency Spectrum chart referred to as operating documents). Unmanned Aircraft System
wrk2play productions , llc plans to operate a UAS, the PHANTOM 3/Q5004K, which is comprised of an unmanned aircraft (UA S or Phantom 3/Q5004K) and a transportable ground station. The Phantom 3/Q5004K is referred to as a quad

- copter with a maximum gross weight of about 3

-4 pounds. It is equipped with four rotors that are driven by electric motors powered by batteries. The UA has a maximum airspeed of 30 knots.

 wrk2play

Productions will only

operate in reasonably

s afe environments that are strictly controlled, are away

f rom power lines, elevated lights, airports and actively populated areas; and

 wrk2play

Productions will conduct extensive preflight inspections and protocols, during which safety carries primary importance.

wrk2play productions , llc states that given the size, weight, speed, and limited operating area associated with the aircraft to be utilized by him, an exemption from 14 CFR part 21, Subpart H (Airworthiness Certificates) and § 91.203 (a) and (b) (Certifications required), subject to certain conditions and limitations, is warranted and meets the requirements for an equivalent level of safety under 14 CFR part 11 and Section 333 of P.L. 112

- 95 (Section 333). Petitioner requests an exemption from § 45.23 Marking of the aircraft because his UA will not have a cabin, cockpit or pilot station on which to mark certain words or phrases. Further, he states that two
-inch lettering is difficult to place on such a small aircraft with dimensions smaller than the minimal lettering requirement. Regardless of this, wrk2play productions states that he will mark his UAS in the largest possible lettering by placing the word “Experimental” on its fuselage as required by §- 7
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45.29(f) so that he or anyone assisting him as a spotter will see the markings. The petitioner states that an exemption from §§ 91.405(a), 91.407(a)(1), 91.409(a)(2) and 91.417(a) and (b) Maintenance inspections may b e required and should be granted since they only a pply to aircraft with an airworthiness certificate. However, wrk2play productions states as a safety precaution he will perform a preflight inspection of his UAS before each flight as outlined in his operating documents. UAS Pilot in Command (PIC)

wrk2play productions asserts that under § 61.113 (a) and (b) private pilots are limited to noncommercial operations, however he can achieve an equivalent level of safety as achieved by current regulations because his UAS does not carry any pilots or passengers. Further while helpful, a pilot license will not ensure remote control piloting skills. We believe that the risks of operating a UAS are far less than the risk levels inherent in the commercial activities outlined in 14 CFR part 61, et seq., thus he requests an exemption from § 61.113 Private Pilot Privileges and Limitations; Pilot in command. Regarding UAS operational training, wrk2play productions has flown numerous practice flights in remote areas as a hobbyist simulating flights for future commercial use to gain familiarization with the characteristics of his UAS’ performance under different temperature and weather conditions. He further states that he practices computerized simulated flights to maintain adequate skills and response reflex time. The PIC (s) for wrk2play productions currently hold an FAA Airman’s certificate with a current Utah State driver’s license and/or class 3 medical or higher. UAS Operating Parameters

wrk2play productions, llc will abide by the following additional operating conditions under this exemption:

 Operate the UAS below 400 feet and within a radium distance of 1 5 00 feet (Within VLOS) from the controller to aid in direct line of sight visual observation

.  Operate the UA S for 10

- 15 minutes per flight.  Land the UAS prior to the manufacturer’s recommended minimum level of battery power;  Operate the UAS only within visual line of sight (VLOS);  Use the UAS’ global positioning system (GPS) (GLONASS) flight safety feature whereby it hovers and then slowly lands if communication with the remote control pilot is lost;  C onduct all operations under his own personal and flight safety protocols (including posting a warning sign reading: “Attention Aerial Photography in Progress

– Remain Back 25 feet”) contained in the operating documents and will actively analyze flight data and other sources of information to constantly update and enhance his safety protocols;  Contact respective airports if operations will be within 5 miles to advise them of his estimated flight time, flight duration, elevation of flight and other pertinent information;  Always obtain all necessary permissions prior to operation; and- 8

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 Have procedures in place to abort flights in the event of safety breaches or potential danger.

wrk2play productions , llc states that § 91.7(a) prohibits the operation of an aircraft without an airworthiness certificate. wrk2play productions asserts that since there is currently no certificate applicable to this sUAS , this regulation isn’t applicable

. 91.9(b)(2) requires an aircraft flight manual in the aircraft, however since there are no pilots or passengers on board his aircraft and given its size, this regulation isn’t applicable

. wrk2play productions can maintain an equivalent level o f safety

by maintaining the sUAS and included ground stations . Public Interest Aerial videography and photography for geographical awareness , personal use and for real estate marketing has been around for a long time through manned fixed wing aircraft and helicopters , but for small business owners, its expense has been cost
-prohibitive. Granting this exemption to wrk2play productions would allow us to provide this service at a much lower cost. Further small UAS will pose no threat to the public given its small size and lack of combustible fuel when compared to larger manned aircraft. Operation of this UAS will minimize ecological damage and promote economic growth by providing information to companies and individuals within the State of Utah and the United States of America

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__________________ ____ Sean G. Price Operations Officer/Pilot wrk2play productions, llc 2085 South 50 East Wanship, Utah 84017 435

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-4020 seangprice@gmail.com wrk2play pc@gmail.com